Early PI Warning Signs Most Practices Ignore in February
It Is February. You Still Have Time.
It is February. That means one thing for your practice. The year is still young, but your Promoting Interoperability, or PI, clock is already ticking.
Most teams tell me the same thing this time of year:
“We will look at PI after we settle quality.”
“We just upgraded the EHR, so we should be fine.”
“Our vendor tracks that.”
Here is the truth. February is when small PI mistakes start. If you catch them now, you protect your MIPS score. If you ignore them, they grow quietly.
Since 2025, PI has become more focused on real data exchange, stronger cybersecurity, and accurate reporting under APP and APP Plus. The rules are more detailed. The margin for error is smaller.
Let us walk through the early warning signs you should check right now.
How PI Has Changed Since 2025
PI today is not the same as it was a few years ago.
Since 2025, CMS has:
Tightened expectations around health information exchange
Increased focus on documented Security Risk Assessments
Required stronger proof of certified EHR use
Aligned PI reporting more closely with ACO APP and APP Plus models
Emphasized real patient access, not just portal activation
What does that mean for you?
It means CMS wants proof that your systems actually work. Not that you own them. Not that you turned them on. But that your team uses them correctly, every day.
Many practices overlook subtle changes in measure language. A tiny reporting nuance can lower your numerator. A small denominator error can reduce your score.
Now, let us look at the early warning signs.
1. Your Security Risk Assessment Is “On the Calendar”
In February, we ask one question:
Have you completed your Security Risk Assessment for this performance year?
If the answer is no, you are already behind.
A Security Risk Assessment is not just an IT task. It is required for PI. It must include:
Administrative safeguards
Physical safeguards
Technical safeguards
A remediation plan
Since 2025, auditors have been reviewing documentation more closely. They want proof that the risks were identified and addressed.
Early Warning Sign:
Your last SRA was done late in the year.
You have no written remediation tracking.
Leadership has not reviewed cybersecurity risks.
Action Step for February:
Complete your SRA now.
Document each risk clearly.
Assign a person to track fixes.
Set a monthly check-in on progress.
Do not wait for summer. If you find gaps, you need time to correct them.
2. Your Health Information Exchange Rate Looks “Good Enough”
Health Information Exchange, or HIE, is where many practices quietly lose points.
CMS expects that when you send a patient to another provider, you electronically send a summary of care. Not by fax. Not by printout.
Since 2025, CMS has made it clear. Interoperability must be electronic and consistent.
Early Warning Sign:
Staff says fax is faster.
Referral summaries are not tracked monthly.
Your HIE rate is below 90%.
Even an 80 percent rate can hurt you.
Action Step for February:
Pull a 30-day referral report.
Match referrals to electronic transmission logs.
Retrain staff who skip the exchange step.
Disable default fax options when possible.
Make HIE part of the workflow. Not an extra step.
3. Your E-Prescribing Numbers Do Not Match Reality
Electronic prescribing sounds simple. But small workflow gaps cause big reporting issues.
Common problems we see:
Locum providers are not mapped in the system.
Controlled substances sent through a separate tool.
Refill requests handled outside the certified EHR.
Since 2025, CMS reporting logic is less forgiving. If prescriptions are not documented correctly in Certified Electronic Health Record Technology, they may not be counted.
Early Warning Sign:
Your denominator seems lower than expected.
New providers were added without full configuration.
You rely on pharmacy reports instead of EHR reports.
Action Step for February:
Confirm all providers are active in the certified system.
Compare pharmacy logs to EHR prescribing data.
Standardize controlled substance workflows.
If your numbers look “too clean,” double-check them.
4. Your Patient Portal Is Active but Not Used
Patient access is not about sign-ups. It is about use.
Since 2025, CMS expects patients to access their data electronically. That means viewing, downloading, or transmitting information.
If patients activate accounts but never log in, your score may drop.
Early Warning Sign:
High enrollment, low login rates.
Patients report being unable to find results.
No one reviews portal activity reports.
Action Step for February:
Run a monthly portal activity report.
Train staff to walk patients through the first login before they leave.
Send follow-up reminders after visits.
Post simple instructions on your website.
Engagement should be simple. If it is hard, patients will not use it.
5. You Are Not Tracking PI Monthly
This is the biggest red flag.
If you only look at PI data before submission, you are guessing.
Since 2025, reporting thresholds have left less room for error. A few missed weeks can lower your annual rate.
Early Warning Sign:
No monthly PI dashboard.
No assigned PI owner.
Reports pulled only at year-end.
Action Step for February:
Assign one PI lead.
Schedule a 20-minute monthly review.
Track:
HIE rate
E-prescribing rate
Portal activity
SRA remediation
Small checks prevent big losses.
6. Your EHR Update Is Delayed
CMS requires the use of certified EHR technology.
If your vendor upgraded in January and your team postponed implementation, that creates risk.
Early Warning Sign:
Some providers use old templates.
Reporting modules are not activated.
You do not have written confirmation of certification status.
Action Step for February:
Request written confirmation of certification from your vendor.
Confirm that all providers use the same version.
Test your reporting functions now, not in December.
A version mismatch can invalidate your submission.
Why ACO Practices Must Be Extra Careful
If you are part of an Accountable Care Organization, PI connects to more than MIPS.
PI supports:
Accurate APP or APP Plus reporting
Clean attribution data
Coordinated care documentation
Shared savings performance
If your interoperability fails, your ACO reporting can suffer.
February is when you protect alignment.
A Simple February PI Optimization Plan
Pause here. Ask yourself these questions:
Did we complete this year’s Security Risk Assessment?
Are we auditing HIE monthly?
Are all providers mapped correctly for e-prescribing?
Are patients actually using the portal?
Do we have a named PI owner?
If any answer is no, start today.
Here is a simple 30-day plan:
Week 1: Complete or review SRA.
Week 2: Audit referrals and HIE logs.
Week 3: Validate prescribing data.
Week 4: Review portal engagement and retrain staff.
Then repeat monthly.
February Is Your Advantage
PI problems rarely start in October. They start now. In February. When teams assume there is time.
Since 2025, PI has become more precise. CMS expects stronger cybersecurity, real electronic exchange, and consistent patient access. The details matter. Small workflow gaps can lower your score.
The good news is simple. You can fix most issues in the first quarter.
If you want a structured PI review tailored to your practice or ACO, Chirpy Bird can help you identify risks early and optimize performance before they become reimbursement issues.
February is not too early. It is the right time.
